This proceeding involves deficiencies in income taxes for the years 1948 and 1949 in the amounts of $631.19 and $477.69, respectively, and penalties for the year 1948 under the provisions of section 294 (d) (1) (A) of the Internal Revenue Code in the amount of $155.43, and under section 294 (d) (2) in the amount of $93.26. The deficiencies arise because of the disallowance of deductions taken by petitioner. The deductions consisted of payments which the petitioner made to...
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